Compliance and Ethics in Action

Because Fluor understands that the Fluor Code of Business Conduct and Ethics (The Code) cannot possibly cover every subject area or situation, the company strives to ensure that individuals know the right questions to ask, the right experts to consult, and the right way to make decisions.

Employee Decision-Making Model

If ever in doubt, Fluor personnel are instructed to ask:

  • Is this legal? Have I checked with the company's subject matter expert?
  • Would it conflict with any of Fluor's core values: safety, integrity, teamwork or excellence?
  • Am I involving the right people?
  • How would I feel telling my family or children about my decision?
  • If I choose to act on this situation, would my decision be fair?
  • How would I feel reading about my choice in a newspaper, or explaining my choice to a judge or jury?
  • If you know it's wrong, don't do it.
  • If in doubt, ASK.
  • Keep asking until you get an answer.
  • Don't ignore what you believe to be illegal or unethical conduct.
  • Set an example for others.

Take responsibility by DOING THE RIGHT THING. For managers, this includes taking responsibility for having the proper and necessary policies, procedures and an environment to DO THE RIGHT THING.

Employee Training

Training is one of the most critical components for the success of any ethics and compliance program. Fluor's training program has a multi-topic curriculum to ensure employees understand the risks that apply to their positions and comply with the related Fluor policies and practices.

All Fluor salaried employees receive Code training, with an emphasis on anti-corruption and other key risk areas.

Managers receive additional training on how to handle and escalate employee concerns about misconduct in a way that reinforces the company's commitment to maintaining an open and non-retaliatory workplace.

Additionally, employees are asked to participate in specialty, web-based training modules that focus on key risk areas related to their job function at Fluor. Face-to-face training classes are also conducted, including project-specific, anti-corruption training, as well as other classes focused on ethics and compliance risk areas for targeted employees and directors. These training materials are periodically refreshed. The company-wide Ethics & Compliance Training and Certification is updated every year to train employees on trending issues in compliance and address frequently asked compliance and ethics questions or reported concerns.

We assess the effectiveness of our training program on an ongoing basis. This includes assessing contacts to the hotline, employee surveys and business needs.

Employee Certification

As part of our ongoing commitment to adhere to the highest standards of business conduct and ethics, our employees are asked annually to review Fluor's Code of Business Conduct and Ethics to ensure their understanding of the company's commitment to integrity and ethics and to certify to their understanding and adherence to the Code. This practice also requires employees to disclose ethical concerns and actual or potential conflicts of interest for resolution.

Conflicts of Interest

All new hires and re-hires are required to disclose any conflicts of interest during the on-boarding process. Additionally, employees are asked to disclose any actual or potential conflicts of interest during the annual ethics certification process.

All disclosures are reviewed by the appropriate department (i.e., Human Resources, Corporate Compliance or the Law Department) and guidance is issued to employees. This process is overseen by the Chief Compliance Officer.

Employees are not precluded from seeking elected positions provided that they disclose the matter and comply with Fluor's Code of Conduct and conflicts of interest policy. Fluor does not, however, hire any current government officials as consultants, directors or employees.

Seeking Advice and Reporting Concerns

It is of the highest importance to Fluor that employees seek guidance if they are ever unsure about the right thing to do in a business situation and that they are willing to readily report concerns about suspected unethical behavior. In addition to encouraging personnel to speak with their immediate supervisor, others in management, Human Resources, Industrial Relations, a Fluor subject-matter expert or an investigating department, our company has in place a toll-free Compliance and Ethics Integrity Portal to facilitate reporting, anonymously where permitted by local law, and seeking advice around the globe. Fluor will not tolerate any form of direct or indirect retaliation that arises from anyone reporting suspected illegal or unethical conduct in good faith.

Clients, partners, suppliers, and subcontractors also are encouraged to report any suspected misconduct involving or affecting Fluor, whether or not the concern involves the supplier or contractor, by contacting their Fluor representative, Fluor's Chief Procurement Officer (for suppliers and contractors) or Fluor's Compliance and Ethics Integrity Portal.